As an organisation approved by a Member State in accordance with Annex IV (Part-147) of Regulation (EU) 1321/2014 and my principal place of business is within the territory of the EU, am I allowed to provide training to Russian citizens?
In principle, it is prohibited to provide technical assistance related to maintenance, directly or indirectly to any natural or legal person, entity or body in Russia or for use in Russia (ref. Art. 3(4)(a) of Regulation (EU) 833/2014). Training of maintenance personnel could be allowed if done for the purpose of later working for a maintenance organisation subject to Regulation (EU) 1321/2014 outside Russia. If the purpose of the training is to work in Russia or on Russian aircraft subject to the restrictive measures, such training provision is prohibited. Furthermore, the training cannot take place in Russia.